Constitutional personal-liberty safeguards limit PMLA twin bail conditions where completed investigations lead to prolonged incarceration before trial...
Automated airline software subscriptions without human intervention fail technical-services characterisation and do not make available underlying tech...
Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to Revenue and cannot merely replace one plausible view with another. Deduction for contributions to a Core Settlement Guarantee Fund required enquiry into whether payment created an accrued business liability or constituted a corpus for potential future defaults. Examination of genuineness and reasonableness alone was insufficient, given the fund's segregation, accumulated corpus and interest income. The ITAT sustained limited revision because the Assessing Officer had not undertaken requisite verification, directing fresh examination after hearing the assessee while leaving deductibility open.
Revisionary jurisdiction requires an assessment order to be both erroneous and prejudicial to Revenue and cannot merely replace one plausible view with another. Deduction for contributions to a Core Settlement Guarantee Fund required enquiry into whether payment created an accrued business liability or constituted a corpus for potential future defaults. Examination of genuineness and reasonableness alone was insufficient, given the fund's segregation, accumulated corpus and interest income. The ITAT sustained limited revision because the Assessing Officer had not undertaken requisite verification, directing fresh examination after hearing the assessee while leaving deductibility open.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4910 
